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Courts: ITAT Mumbai

5,841 articles
Income TaxArm’s length price should be based on the functional and asset profile of the company
Income Tax

Arm’s length price should be based on the functional and asset profile of the company

TG Team16 years ago
Income TaxPrescribed methods to be followed for ALP determination and interest on outstanding trade balances not the same as interest on loan
Income Tax

Prescribed methods to be followed for ALP determination and interest on outstanding trade balances not the same as interest on loan

TG Team16 years ago
Income TaxProvision made for bad and doubtful debts to be included in the ‘Book Profit’ for the purpose of MAT
Income Tax

Provision made for bad and doubtful debts to be included in the ‘Book Profit’ for the purpose of MAT

TG Team16 years ago
Income TaxNo Penalty for bonafide difference of opinion in selection of transfer pricing method
Income Tax

No Penalty for bonafide difference of opinion in selection of transfer pricing method

TG Team16 years ago
Income TaxIf thin capitalization rules are not in the domestic law/Treaty, there can be not be artificial disallowance of interest paid on borrowings
Income Tax

If thin capitalization rules are not in the domestic law/Treaty, there can be not be artificial disallowance of interest paid on borrowings

TG Team16 years ago
Income TaxNational Aviation Co. of India Vs. DCIT (ITAT Mumbai)
Income Tax

National Aviation Co. of India Vs. DCIT (ITAT Mumbai)

TG Team16 years ago
Income TaxTaxpayer can remit monies abroad without tax deduction if it is of  opinion that remittance is wholly exempt from tax
Income Tax

Taxpayer can remit monies abroad without tax deduction if it is of opinion that remittance is wholly exempt from tax

TG Team16 years ago
Income TaxPayment received by taxpayer for sale of shrink wrapped software is not  royalty under Article 12(3) of the India-USA tax treaty
Income Tax

Payment received by taxpayer for sale of shrink wrapped software is not royalty under Article 12(3) of the India-USA tax treaty

TG Team16 years ago
Income TaxHC requests ITAT President to make it compulsory for assessees to amend Form 36 for change of address instead of merely intimating vide letter
Income Tax

HC requests ITAT President to make it compulsory for assessees to amend Form 36 for change of address instead of merely intimating vide letter

TG Team16 years ago
Income TaxHigher price paid to AEs accepted as ALP under the CUP Method, provided there is sufficient economic and commercial justification evidencing the same
Income Tax

Higher price paid to AEs accepted as ALP under the CUP Method, provided there is sufficient economic and commercial justification evidencing the same

TG Team16 years ago
Income TaxNo disallowance u/s. 40(a)(ia) where payments made were apparently less than Rs. 20,000 each and to each party less than Rs. 50,000 per year, as per t
Income Tax

No disallowance u/s. 40(a)(ia) where payments made were apparently less than Rs. 20,000 each and to each party less than Rs. 50,000 per year, as per t

TG Team16 years ago
Income TaxMere existence of subsidiary company in India does not constitute subsidiary company as PE of Parent company
Income Tax

Mere existence of subsidiary company in India does not constitute subsidiary company as PE of Parent company

TG Team16 years ago
Income TaxPayment made to USA entities cannot be disallowed on account of non deduction of tax at source
Income Tax

Payment made to USA entities cannot be disallowed on account of non deduction of tax at source

TG Team16 years ago
Income TaxDisallowance under section 14A and for expenses for increase in share capital not attracted in the case of life insurance companies
Income Tax

Disallowance under section 14A and for expenses for increase in share capital not attracted in the case of life insurance companies

TG Team16 years ago